ML20207N774
| ML20207N774 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 01/08/1987 |
| From: | Fay C WISCONSIN ELECTRIC POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION (ADM) |
| Shared Package | |
| ML20207N776 | List: |
| References | |
| CON-NRC-87-004, RTR-NUREG-0737, TASK-2.F.1, TASK-TM GL-83-37, VPNPD-87-008, NUDOCS 8701140415 | |
| Download: ML20207N774 (4) | |
Text
O lMsconsin Electnc eaara couesur 231 W. MICHIG AN, P.O. BOX 2046, MILWAUKEE, Wl 53201 (414)277 2345 VPNPD-87-008 NRC-87-004 January 8, 1987 CERTIFIED MAIL U. S. NUCLEAR REGULATORY COMMISSION Document Control Desk washington, D.
C.
20555 Gentlemen:
DOCKETS 50-266 AND 50-301 TECHNICAL SPECIFICATION CHANGE REOUEST 114 CONTAINMENT HYDROGEN MONITORS AND ADMINISTRATIVE CHANGES POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 In accordance with the requirements of 10 CFR 50.59 and 50.90, Wisconsin Electric Power Company (Licensee) hereby submits an application for amendments to Facility Operating Licenses DPR-24 and DPR-27 for the Point Beach Nuclear Plant, Units 1 and 2.
The purpose of these amendments is to incorporate changes to Technical Specification-15.3.5, " Instrumentation System."
Attached are Technical Specification pages containing the proposed changes, which are identified by margin bars.
Our proposed change to Table 15.3.5-5, Item 10, " Containment Hydrogen Monitors", consists of changing the number of channels (as listed) from four to two.
Although we currently do not have plans for removing any hydrogen. channels from service (i.e., four channels remain installed), the proposed change would require that two of these four channels be operable to meet the requirements of the Technical Specifications.
The NRC issued NUREG-0737, " Clarification of TMI Action Plan Requirements", in November 1980.
Item II.F.1, Attachment 6, listed design and qualification criteria for the Containment Hydrogen Monitoring System (CHMS) and indicated that changes to Okh 0k qh$
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9 USNRC Document Control Desk January 8, 1987 Page 2 Technical Specifications would be required.
In subsequent
' correspondence and meetings between Wisconsin Electric and the NRC staff, we outlined the CHMS design chosen for Point Beach Nuclear Plant.
Our design was a four-monitor system (within each containment) powered by two independent trains.
The reason four channels were installed was to allow two channels to be removed from service and sent to a vendor for calibration during unit operation.
(It has subsequently been determined that the detectors can be calibrated on site during refueling outages.)
NRC review of our design found that it met the requirements of NUREG-0737.
This review was documented in your Safety Evaluation dated June 21, 1983.
On November 1, 1983, the NRC issued Generic Letter 83-37, "NUREG-0737 Technical Specifications", which gave guidance on the scope of Technical Specifications required for TMI items scheduled for implementation after December 31, 1981.
Regarding the CHMS, the Generic Letter listed the acceptable number of monitor channels as two, stating: "Two independent containment hydrogen monitors should be operable at all times when the reactor is operating in Power Operation or Startup Modes."
Guidance on LCO action statements relative to this statement was also provided.
Subsequently we submitted a Technical Specification Change Request (dated December 16, 1983; modified April 6, 1984) listing our proposed Technical Specifications for TMI items.
Our request listed the "No. of Channels" for containment hydrogen monitors as four, " Minimum Operable Channels" as one, and an operator action statement addressing the situation where the minimum operable channels cannot be met.
The change was approved July 18, 1985.
l Our proposed change to the Technical Specifications would allow I
us to use any two of the four hydrogen monitors to meet the Technical Specification requirement for operable hydrogen monitors.
By maintaining two redundant channels, we will still meet the NRC guidance set forth in Generic Letter 83-37.
We are also proposing an administrative change to Table 15.3.5-2, " Instrument Operation Conditions for Reactor Trip."
Item 10 specifies instrument conditions necessary for a reactor trip on low flow,in one or both loops. The change adds clarifying information to Column 3, " Minimum Operable Channels" (2/ loop for both the 10-50% and >50% power condition) and to Column 4, " Minimum Degree of Redundancy" (1/ loop for both the 10-50% and >50% power condition).
Also, the Column 2 (No. of l
Channels to Trip) entry for the 10-50% condition is changed from "2/ loop (any loop)" to "2/ loop (both loops)."
This ccrrects the previous erroneous entry, as low flow in both l
loops must exist for a reactor trip to occur in the 10-50%
power condition.
1
USNRC Document Control Desk 4
- January 8, 1987 Page 3 In addition to'these changes, we sre also' proposing two other unrelated changes of an administrative nature.
Table 15.3.5-2 lists Item 2,." Nuclear Flux Power Range", with a double asterisk, denoting a footnote.
The footnote to Item 2 states that an additional power range channel may be taken out of service for zero power physics' testing.
Our proposed change would revise the footnote wording to read "... low power physics testing."
This change would achieve consistency throughout the Technical Specifications relative to power limitations during physics testing.
The somewhat ambiguous."zero power" term would be replaced with thelbetter-established and understood
" low power" term, which-is presently defined in Technical
- Specification 15.1.n.
The second change involves revision of Table 15.3.5-1,
" Engineered Safety Feature Initiation Instrument Setting
- Limits."
The setting limit column entries for Items 9, 10a, and 10b have been revised to remove ambiguity existing-in the present wording.
Item 9 additionally contains an editorial correction changing the word "of" to "at".
Items 10a and 10b also contain revisions to the time delay setting which reflect the intention of the time delay inequality tolerance in more positive terms.
The footnote to this page has also been-removed as it is no longer applicable due to the passage of time since the table was last amended.
We have examined this license amendment application and Technical Specification Change Request with respect to the-criteria of 10 CFR 50.92 and have determined that this amendment will not result in a significant hazards consideration.
The first criterion concerns changes involving a significant increase in the probability or consequences of l_
an accident previously evaluated.
The proposed amendments are i
administrative in nature and involve no physical alteration or procedure change which could, in any way, increase the L
probability or consequences of a previously evaluated accident.
l The second criterion involves creating the possibility of a new or different kind of accident from an accident previously evaluated.
Again the changes, by their nature, cannot result in a new or different kind of accident.
The third criterion l
concerns a significant reduction in a margin of safety.
j Concerning the proposed reduction in hydrogen monitor channels 1
as recognized ~by'the Technical Specifications, margin of safety is not reduced as the guidance set forth by the NRC in Generic Letter 83-37 is still met.
The other proposed changes to the j
Technical Specifications, by their very nature, cannot affect the magnitude of the margin in safety.
They merely alter I
present wording to produce clarity and continuity in the j
specifications as well as remove ambiguity.
r
USNRC Document Control Desk January 8, 1987 Page 4 We have enclosed a check in the amount of $150 for the application fee prescribed in 10 CFR 170.
Please contact us if you have any questions concerning this request.
Very truly yours,
/d /
C. W. Fa'y 0
Vice Pr sident Nuclear ?ower Enclosure (Check 936743)
Copies to NRC Regional Administrator, Office of Inspection and Enforcement, Region III NRC Resident Inspector R.
S.
Cullen, PSCW Subscrihed and sworn to before me this 1
- day of January, 1987.
Aw w
ww Notary Public, Statd)df Wisconsin My Commission expires Sn-2 7-96.
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